Opinion
Case No. 3:12-cv-50064
06-11-2012
UNITED STATES OF AMERICA, Plaintiff, v. BMO HARRIS BANK N.A. f/k/a HARRIS BANK N.A. AS SUCCESSOR IN BUSINESS TO AMCORE BANK N.A., f/k/a AMCORE TRUST COMPANY, SUCCESSOR TO DIXON NATIONAL BANK, AS TRUSTEE UNDER AGREEMENT DATED APRIL 19, 1977 KNOWN AS TRUST NO. 1058, and not personally; UNKNOWN OWNERS; and NONRECORD CLAIMANTS; Defendants.
PATRICK J. FITZGERALD United States Attorney By: KIMBERLY J. GOODELL Attorney for the United States 223 W. Jackson Blvd., Suite 610 Chicago, IL 60606
MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE
NOW COMES, Plaintiff, UNITED STATES OF AMERICA, by and through its attorneys, Potestivo & Associates, P.C., and moves this Honorable Court, for the Entry of a Judgment of Foreclosure.
Attached please find Plaintiff's Affidavit of Prove-Up. (See Exhibit "1", Affidavit).
Respectfully submitted,
PATRICK J. FITZGERALD
United States Attorney
By: KIMBERLY J. GOODELL
Attorney for the United States
223 W. Jackson Blvd., Suite 610
Chicago, IL 60606
CERTIFICATE OF SERVICE
I, Kimberly J. Goodell, certify that a true and correct copy of the foregoing MOTION FOR ENTRY OF JUDGMENT OF FORECLOSURE was served upon counsel of record through operation of the Court's Case Management/Electronic Case Files system on June 11, 2012, and on the following non-ECF filers:
Colleen Hennessy, Registered Agent
BMO HARRIS BANK N.A. f/k/a HARRIS
BANK N.A. AS SUCCESSOR IN
BUSINESS TO AMCORE BANK N.A.,
f/k/a AMCORE TRUST COMPANY,
SUCCESSOR TO DIXON NATIONAL
BANK, AS TRUSTEE UNDER
AGREEMENT DATED APRIL 19, 1977
KNOWN AS TRUST NO. 1058, and not personally;
111 West Monroe Street, 22nd Floor
Chicago, Illinois 60603
Louise F. Gotsch, Land Trust Administrator
BMO HARRIS BANK N.A. f/k/a HARRIS
BANK N.A. AS SUCCESSOR IN
BUSINESS TO AMCORE BANK N.A.,
f/k/a AMCORE TRUST COMPANY,
SUCCESSOR TO DIXON NATIONAL
BANK, AS TRUSTEE UNDER
AGREEMENT DATED APRIL 19, 1977
KNOWN AS TRUST NO. 1058, and not personally;
501 7th Street
Rockford, Illinois 61104-1242
Unknown Owners and NonRecord Claimants
601 Countryside Lane
Dixon, Illinois 61021
By: KIMBERLY J. GOODELL
Potestivo & Associates, P.C.
Attorneys for Plaintiff
223 W. Jackson Blvd., Suite 610
Chicago, Illinois 60606